Case Digest (G.R. No. 176703)
Facts:
Municipality of Cainta v. City of Pasig and Uniwide Sales Warehouse Club, Inc., G.R. Nos. 176703 & 176721, January 29, 2018, Supreme Court Second Division, Martires, J., writing for the Court.Uniwide Sales Warehouse Club, Inc. (Uniwide) owned or operated business on parcels covered by TCT Nos. 72983, 74003, and PT-74468 (the subject properties), whose certificates of title indicate the parcels are located in Pasig. Uniwide obtained building and mayor’s permits from Pasig, and paid Pasig business and real property taxes from 1989 to 1996. Beginning 1997 Uniwide stopped renewing permits in Pasig and, after receiving notice from Cainta that the properties lay within its territory, began paying local taxes to Cainta. On 6 May 1999 Uniwide sold the subject properties to Robinsons Land Corporation.
On 28 January 1997 Pasig filed a tax-collection complaint in the Regional Trial Court, Branch 267, Pasig City (RTC-Pasig) against Uniwide for unpaid local business taxes, fees and other charges for fiscal year 1997. Uniwide impleaded Cainta by way of third-party complaint seeking reimbursement of any amounts Uniwide paid to Cainta should Uniwide be held liable to Pasig. Prior to the tax suit, Cainta had filed a boundary-dispute petition against Pasig in RTC, Branch 74, Antipolo City (RTC-Antipolo) on 30 January 1994; the subject properties were among the disputed areas.
In the tax case Cainta moved to dismiss or suspend the proceedings (6 November 2001) on grounds of litis pendentia and prejudicial question; the RTC-Pasig denied the motion (22 January 2002) and denied reconsideration (7 March 2002). Cainta then filed a Rule 65 petition for certiorari in the Court of Appeals (CA-G.R. SP No. 70408) seeking TRO/preliminary injunction; the CA issued no TRO and dismissed the petition on 30 September 2004.
The RTC-Pasig, in a 30 June 2003 decision, upheld the indefeasibility of the Torrens titles showing the properties in Pasig, ordered Uniwide to pay Pasig local taxes and attorney’s fees (₱500,000), and ordered Cainta to reimburse Uniwide the amounts Uniwide had paid Cainta (plus ₱500,000 attorney’s fees) under unjust-enrichment principles. Motions for partial reconsideration were denied (30 October 2003). On appeal the Court of Appeals, in a 12 July 2006 decision, affirmed the RTC judgment but reduced each attorney’s-fees award to ₱100,000; it...(Subscriber-Only)
Issues:
- Did the pendency of the boundary-dispute case (and Cainta’s Rule 65 petition) require dismissal or suspension of the RTC-Pasig tax-collection proceedings on grounds of litis pendentia, forum shopping, or prejudicial question?
- May the RTC-Pasig and the Court of Appeals properly determine Pasig’s apparent right to collect local taxes by relying on the locational entries in the Torrens certificates of title (TCTs) despite the pending boundary case, and were the courts correct in directing Uniwide to pay Pasig and ordering Cainta to reimburse Uniwide?...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
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Doctrine:
- (Subscriber-Only)